Christine Crabtree, V. Donald Crabtree

CourtCourt of Appeals of Washington
DecidedJune 9, 2025
Docket86664-8
StatusUnpublished

This text of Christine Crabtree, V. Donald Crabtree (Christine Crabtree, V. Donald Crabtree) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christine Crabtree, V. Donald Crabtree, (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

In the Matter of the Marriage of: No. 86664-8-I CHRISTINE CRABTREE, DIVISION ONE Respondent, UNPUBLISHED OPINION and

DONALD CLINTON CRABTREE,

Appellant.

HAZELRIGG, C.J. — In his fourth post-dissolution appeal, Donald Crabtree

challenges the trial court’s entry of a permanent parenting plan. Because he fails

to establish that the trial court abused its discretion by entering a parenting plan

that maintains restrictions on his in-person visitation with his children until he

complies with court-imposed requirements pertaining to his use of physical

discipline, we affirm.

FACTS

This appeal resumes litigation of modifications to a parenting plan. 1 Our

opinion in the prior appeal provides the following relevant background facts:

1 See In re Marriage of Crabtree, No. 80165-1-I (Wash. Ct. App. Apr. 20, 2020)

(unpublished), https://www.courts.wa.gov/opinions/pdf/801651.pdf; Crabtree v. Crabtree, No. 81164-9-I (Wash. Ct. App. Aug. 2, 2021) (unpublished), https://www.courts.wa.gov/opinions/pdf/ 811649.pdf; In re Marriage of Crabtree, No. 84155-6-I (Wash. Ct. App. June 26, 2023) (unpublished), https://www.courts.wa.gov/opinions/pdf/841556.pdf. No. 86664-8-I/2

Donald and Christine Crabtree[2] dissolved their marriage in 2018. A South Carolina court entered a final custody order that provided for the parties’ four dependent children to live primarily with Christine and to reside with Clint every other weekend. Soon after the entry of this order, both parties relocated to Washington State. In 2020, based on Clint’s acknowledged use of physical discipline against the parties’ oldest child, in violation of an express provision of the 2018 South Carolina custody order, the superior court entered a restraining order suspending his visitation with the children, who were then between the ages of 6 and 12, and also found him to be in contempt. The restraining order provided that Clint could petition the court to resume his residential time after he completed a court-approved parenting class, and submitted a declaration to the court acknowledging that physical discipline constitutes corporal punishment and stating that he will not administer corporal punishment to the children (consistent with the terms of the 2018 South Carolina order). In the interim, the 2020 order allowed him two telephone or video calls per week with the children, during specific one-hour windows. A year later, when Clint still had not submitted the required declaration, the court reissued a protection order that included the same provisions. In 2022, when the second restraining order was about to expire, Christine filed a motion for adequate cause to modify the parenting plan. She sought entry of a Washington parenting plan that reflected the provisions of the prior South Carolina court order and also incorporated the provisions of the 2020 and 2021 restraining orders that suspended Clint’s in-person visitation. Christine also requested that she no longer be required to consult with Clint on certain major issues involving the children, as required under the 2018 order. Clint then filed his own motion for an adequate cause determination that sought to modify the parenting plan and motions for contempt, a restraining order, and to appoint a guardian ad litem (GAL). After a hearing, a superior court commissioner granted Christine’s motion for adequate cause and entered her proposed temporary parenting plan. At the same time, the commissioner denied Clint’s motion for adequate cause and his other motions, and specifically found that even if Christine violated provisions of the South Carolina custody order, her violations were not intentional or willfully contemptuous. Clint sought revision of the commissioner’s orders. After a hearing, the superior court denied revision.

2 Because the parties share the same last name, we refer to them by their first names for

clarity. No disrespect is intended. Further, the record in the prior opinion established that Donald Crabtree used his middle name and there we referred to him as Clint. However, in the current case, he refers to himself as Donald and we will refer to him as such.

-2- No. 86664-8-I/3

In re Marriage of Crabtree, No. 84155-6-I, slip op. at 2-3 (Wash. Ct. App. June 26,

2023) (footnotes omitted) (unpublished), https://www.courts.wa.gov/opinions/

pdf/841556.pdf. 3 Donald appealed to this court. Id. at 1. We affirmed the decision

of the trial court and awarded Christine her reasonable attorney fees and costs

pursuant to RAP 18.9(a). Id. at 8-9.

On February 22, 2024, Donald and Christine returned to superior court for

a hearing on her motion to modify the parenting plan. She requested that the court

adopt the temporary parenting plan as the final parenting plan. The plan reflected

the provisions of the restraining orders, including the requirement that Donald

submit a declaration to the court that he would not engage in physical discipline of

the children. As of the hearing, Donald had completed the required parenting

class, but had not submitted the declaration. 4 He had not had in-person visits with

the children since March 2020.

Donald argued that the temporary parenting plan did not reflect the

children’s best interests and there was no basis for the imposed restrictions. As to

the requirement that he enter a declaration that he would refrain from physical

punishment, he attempted to attack the original prohibition on his use of corporal

punishment imposed by the South Carolina court that decided the dissolution and

stated that he would “provide evidence to show that there is no basis for that

3 This opinion is unpublished and cited pursuant to GR 14.1(c) only as necessary for a well-

reasoned opinion. 4 In September 2022, Donald offered a declaration in which he stated he would no longer

apply corporal punishment, but noted that he provided the declaration under duress because it was his religious right and obligation to physically discipline his children. The court did not accept the declaration.

-3- No. 86664-8-I/4

restriction and that it may be best if the [Washington] court were to simply drop the

requirement based off of the evidence.” He also requested a parenting coordinator

to work with the family, rather than reunification counseling.

The trial court noted that three of the Crabtree children were 12 years old

or older and asked, “[I]s there anything being communicated to the court about the

wishes of the children?” Christine responded that nothing had been submitted to

the court by either party. Donald stated that he wanted to testify about “what [he]

believe[d] the children desired.” The court informed Donald that such testimony

would likely be hearsay and inadmissible. Donald inquired whether the court would

accept affidavits from a counselor and the court explained that “a professional

opinion can certainly reference original statements made by a person that would

otherwise be hearsay if they form the basis of an opinion that the expert is testifying

about,” but the expert would “would still need to be subject to cross-examination

and there would have to be some way either [sic] the parties have stipulated to the

submission of the report.” Donald further inquired whether the court would accept

signed and sworn affidavits by the children. The court informed him that an

affidavit is an out-of-court statement and a form of hearsay that does not offer an

opportunity for cross-examination. Additionally, the court noted an obvious

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